ICSID Tribunal declares AFC Investment Solutions' claim against Colombia “Manifestly without Legal Merit” because it was filed late

In AFC Investment Solutions S.L. v. Republic of Colombia (ICSID Case No. ARB/20/16) an ICSID Tribunal found that AFC's claim – submitted after the three-year deadline found in Article 10(5) of the Agreement between the Kingdom of Spain and the Republic of Colombia for the Promotion and Reciprocal Protection of Investments (APPRI) – manifestly lacked legal merit under Rule 41(5) of the ICSID Arbitration Rules.